Rise Statement Opposing Proposed OCFS Host Homes Regulations

On January 29, 2020, OCFS posted proposed Host Homes regulations for a 60-day public comment period. The comment period was extended another 60 days (until May 29, 2020).

We encourage parents to read the regulations and submit a comment by emailing REGCOMMENTS@ocfs.ny.govYou may customize this sample letter.

Rise first learned of the organization Safe Families for Children last spring and our parent reporting team interviewed New York City Director Laura Galt to learn more. Many parents on our team could understand the need for temporary respite care. Some have experienced hardship as parents because of weak family ties, particularly those who grew up in foster care themselves. In particular, our parent leaders have struggled at times to meet their own medical needs because they’ve had no one who could step up to temporarily care for their children. Lack of respite care has led to children’s unnecessary placement in foster care. Once children enter foster care, even on voluntary placements, parents frequently lose control over their family lives. Instead, decision-making is made by state actors. Therefore, expansion of voluntary, temporary respite options for vulnerable parents is something that Rise supports in concept.  

That said, we were alarmed in reviewing the regulations to see a picture of respite provision that is out of sync with parents’ self-identified needs. We oppose these regulations and ask OFCS not to approve them. Instead, we urge OCFS to develop a process to hear directly from parents, youth and community advocates to learn more about parents’ needs and develop a model that better meets them. 

During a short-term crisis, parents at Rise report that their primary need is to be able to place their children with someone familiar. It’s been established that family separation can be traumatic to children, especially if that means placement with a stranger under emergency conditions. Expanding stranger care should not be a goal for OCFS. Instead, OCFS can explore barriers to respite for families with weak family times. At Rise, we see that vulnerable parents could use support to make prospective or emergency arrangements with family acquaintances who are not close friends but who their child already knows through schools, religious organizations, or other community connections. This type of “pod-mapping” has been used effectively in some communities to strengthen mutual aid and accountability. These arrangements can be made in good times, so that vulnerable families know they have a source of support in a crisis. 

Another barrier to temporary respite arrangements is financial. Some family members may not be able to financially support a child during a crisis, or parents may not be comfortable asking family acquaintances to take on that burden. If the primary barrier of potential guardians is financial, OCFS can consider making subsidized guardianship, including with “fictive kin,” possible for short-term respite placements. Just as KinGap has reduced the need for stranger foster care and adoption, short-term subsidized respite through guardianship may obviate the need for Host Homes placements with strangers. 

During a long-term crisis, parents at Rise consider voluntary foster care placements safer for children and parents than Host Homes because foster care placement require judicial oversight, efforts to prevent placement, efforts to place children with kin, and legal representation and services for parents and children. However, parents may not seek voluntary placements because fear that they will not be able to revoke the placement at will, or that they may be charged with neglect or abandonment once child welfare is involved. OCFS can work with parents, advocates and child welfare agencies to examine why voluntary foster care placements are not working to provide respite for families. OCFS can work with child welfare agencies to ensure that voluntary placements are truly voluntary, revocable and not pathways to neglect charges. 

Again, we urge OCFS not to approve these regulations but to create a task force on voluntary placement and respite to better understand families’ needs for respite and to find solutions that make it more likely that parents can access respite in a crisis with someone familiar to their child.

Rise acknowledges the positive intentions behind these regulations and the Safe Families for Children model. However, we cannot support these regulations and the parallel placement system they would spring to life. Stranger care placements with fewer protections and less oversight could increase family separation, stress and trauma. We urge OCFS to instead create a task force—that includes parents and youth—to develop solutions more consistent with family preferences and needs.

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